POLICY PURPOSE:

The purpose of this policy is to ensure compliance with regulations, provide clear direction to faculty and staff for determining Effort when preparing proposals and subsequently verifying Effort, and promote the best possible relationships with sponsoring agencies. As a recipient of federal funding, Colorado State University Pueblo is required to comply with a hierarchy of legislation, regulations, specific agency and program information, and institutional requirements that set the framework for how sponsored awards must be managed.  It is important to understand and apply rules and regulations that include:

1. 2 CFR 200 – Uniform Guidance
2. Agency-specific Guidelines
3. Program-specific guidelines
4. Award terms and conditions
5. Institutional Research Policies, Standard Practices and Procedures

CSU Pueblo is required to adhere to these rules and regulations while providing consistency in managing awards while at the same time allowing for nuances to be addressed between sponsor agreements and institutional practices. Title 2 of the Code of Federal Regulations, also known as Uniform Guidance, 2 CFR 200, is the primary regulation governing grants and cooperative agreements issued by the US Government.  The regulations within Uniform Guidance include Cost Principles that determine allowability of costs and outline what is “reasonable, allocable, consistently treated, and permissible.” All of these requirements are critical and impact the day-to-day management of federal awards and audit requirements.

To ensure consistency in the way costs are allocated to the institution, CSU Pueblo applies the Uniform Guidance to all sponsored agreements, including those from private sources, since government sponsors are not allowed to be charged higher rates than private sponsors.  Internal controls are the mechanisms, rules, and procedures implemented by CSU Pueblo to ensure integrity of financial and accounting information, to promote accountability, and prevent fraud.  To ensure financial compliance in post-award administration, regulations require that all recipients of federal sponsored funding follow prescribed practices regarding the proposing, charging, and reporting of Effort on all awards.

POLICY APPLIES TO (persons affected by):

This policy applies to all University business units, faculty, graduate students, and administrative and professional employees with salary charged to sponsored projects, and to all non-exempt support staff, undergraduate students, and limited duration employees paid on sponsored projects.

DEFINITIONS:

Academic Year: For Effort Reporting purposes, an Academic Year is the period of a faculty member’s appointment. CSU Pueblo faculty are generally appointed for either 9 or 12 months.

Certification: The assertion by a Principal Investigator (PI) or designee that the salaries charged to sponsored projects as direct charges or cost sharing reasonably reflect the Effort expended, work performed, and any allowable paid absences permitted under university policy (e.g., Institutional Base Salary) during the reporting period. These certifications are a required process to accept sponsored funding.

Certification Period: After each fiscal quarter has ended, a Certification Period begins. There are two parts to each Certification Period. Once the period opens, Effort coordinators in the ORSP have 30 days to review each project and process any salary transfers (Past Period Distribution Adjustments, or PPDAs) before the PI is notified that the Project Certification is open for them. Effort Coordinators are expected to communicate with the PIs about any questions. There is then another 30-day time interval for PIs or designees to certify the Effort and salaries charged to their projects during the reporting period.

Committed Effort: Amount or percentage of time an individual has communicated to the sponsor that they will work on a specific sponsored project over a specified period. Commitments are made in the proposal, approved by their respective direct and next-level supervisors, and may be documented by the sponsor in award documents. Changes to Committed Effort must be approved by ORSP and may require sponsor approval if rebudgeting is necessary. In-kind effort contributions must be accounted for in the same manner as other committed effort.

Cost Sharing: Any project costs that are not borne by the sponsor. Cost Sharing of Effort is the provision of faculty and/or staff time and related fringe benefits that were committed and provided in support of a project but are paid by other sources of funding and becomes part of the Effort commitment that is certified. Cost-shared Effort in excess of the commitment made in the proposal is non-reportable to the sponsor and must be approved by appropriate supervisor and next-level supervisor.

Designee: Authorized delegate for certification responsibilities on a specific sponsored project for the Quarterly Project Effort Certifications.

Effort: The proportion of time spent by an academic appointee on any University activity expressed as a percentage of time. 100% Effort is the total time spent on university work within the scope of their academic appointment period (9 or 12 months), regardless of how many or how few hours an individual worked in the reporting period. The total Effort reported for a PI/faculty member will always equal 100%, even if the employee is less than 1.0 FTE. Total Academic Year Effort includes sponsored projects and non-sponsored activities that are funded by the University including work performed outside of normal work hours and work performed off-campus. See Institutional Base Salary (IBS) for more information.

Effort Coordinator: An individual identified at the departmental level that is responsible for monitoring and processing Effort statements for their department.

Effort Reporting: The mechanism used to provide assurance to federal or other external sponsors that salaries charged or cost-shared to sponsored awards are reasonable in relation to the work performed and any allowable paid absences permitted under university policy or emergency guidance during the reporting period.

Fiscal Year: CSU Pueblo’s Fiscal Year is from July 1 – June 30. The project certification cycle runs on the CSU Pueblo Fiscal Year calendar (not the federal fiscal year).

In-Kind Contribution:  Non-cash contributions contributed by a third party, such as when individuals at another organization volunteer their time, equipment, or facilities at no cost to the project. Some examples include, but are not limited to office/laboratory space, equipment, supplies, or effort of employees or students provided by an outside source at no cost.

Institutional Base Salary (IBS): As defined in 2 CFR 200.430(h)(2), IBS is the annual compensation paid by CSU Pueblo for an individual's appointment, whether that individual's time is spent on research, instruction, administration, or other activities. IBS does not include bonuses, one-time payments, or incentive pay.  IBS must be used as the base salary on all grant proposals unless there is a statutory limit on compensation (e.g., NIH cap). See the CSU Pueblo Policy on Institutional Base Salary.

Key Personnel: The PI and other individuals who are responsible for the scientific design, conduct, and execution of a project in a substantive, measurable way, whether or not they request salaries or compensation.

Labor Distribution: An allocation of one’s Efforts to specific general ledger accounts. The general ledger documents Effort in the University’s books and records. Note: Labor distribution requires a conversion of time (i.e., Effort) to dollars (i.e., compensation).

Period of Work Performed: The quarterly reporting period defined as the Fiscal Year quarter during which an employee performs Effort, comprised of July-September (Q1), October-December (Q2), January-March (Q3), and April-June (Q4).

Principal Investigator (PI): A Principal Investigator or PI is the individual with overall responsibility for the preparation, conduct, and administration of a research grant, cooperative agreement, training or public service project, contract, or other sponsored project. Typically, the PI must be a tenured or tenure-track Assistant, Associate, or Full Professor or regular full time staff member. Other individuals may serve as PI with prior approval of the Provost/Executive Vice President of Academic Affairs.

Project: For Effort Reporting purposes, “project” is the unique combination of a fund, activity and sub-activity as set up in the financial system.

Salary Cap: A maximum annual rate of CSU Pueblo salary for full-time Effort that can be charged to an agency's award. The ramification to Effort Reporting is the need to set up a companion cost sharing account to cover salary expenditures over the cap.

Summer Salary: Faculty compensated for 9-month academic appointments are permitted to earn up to an additional three months of summer paid compensation on one or more sponsored and/or non-sponsored activities. Individuals can earn up to the equivalent of three months of additional salary for that Effort, subject to college and sponsor policies and the appropriate college or department level approval. If a faculty member has administrative or other non-sponsor related responsibilities (including vacation or proposal preparation/writing) during the period for which they are requesting summer salary, they are precluded from devoting the maximum allowable 100% Effort to sponsored projects and cannot request the full 100% of 3 months of salary from sponsored projects. Summer salary is not included in IBS.

Supplemental Pay: Any pay awarded to a faculty or staff member which is for activity in addition to that described in their letter of appointment (or subsequent salary increase notifications) as established in the Supplemental Pay Policy.  Supplemental pay is intended for university activity that requires Effort in addition to that defined under the individual’s appointment and above their one hundred (100) percent Effort distribution. Supplemental pay associated with any individual receiving financial support for Effort on a funded grant must be approved by the ORSP and in accordance with agency rules and regulations and institutional policy. 

Voluntary Uncommitted Cost Sharing (VUCS): University faculty or senior researcher Effort that is over and above that which is committed and budgeted for in a sponsored agreement. This differs from mandatory or voluntary committed cost sharing which is cost sharing specifically pledged in the proposal’s budget or award. Effort relating to VUCS does not need to be charged to federal awards or certified.

POLICY:

1. The policy of Colorado State University Pueblo is that all individuals who engage in sponsored projects will comply with federal agency requirements and University policies on Effort Reporting, Cost Sharing, Cost Transfers, Institutional Base Salary, the allocation of direct and indirect costs and sponsoring agency regulations regarding the proposing, charging, and reporting of Effort on those projects.
   
   
2. The Effort devoted to a sponsored project should be consistent with the plan that was proposed to the sponsoring agency and agreed to at the time of the award. All Key Personnel must devote at least a one-percent commitment to that project, with a few exceptions such as equipment grants and dissertation grants. All PIs, faculty, and staff who are involved in proposing, executing, directing, or managing sponsored projects are responsible for:
   1. Understanding the fundamentals of Effort and commitment management and Effort certification.
   2. Proposing, expending, and managing Effort in accordance with the award and all applicable sponsor policies and University procedures.
   3. Completing any required educational programs associated with Effort Reporting.
      
      
3. Effort expended on each project must be certified at the end of specified reporting periods by a responsible person, generally the PI, with suitable means of verification that the work was performed and the salary charges are appropriate. The Effort certification should be a reasonable accounting of how time was expended.
   
   
4. Generally, faculty cannot commit 100% of their Effort to sponsored projects, as time must be reserved for other duties. For Administrative Professionals and State Classified staff, up to 100% of Effort may be devoted to sponsored projects. However, allocations of Effort to sponsored projects must be reasonable given the individual’s non-sponsored University activities.
   
   
5. Effort must be certified for all individuals who receive salary support from a sponsored project and those who expend committed Effort on a sponsored project without receiving salary support from the sponsor. PIs certify the Effort of all staff on each project. Project Effort reports must be certified in a timely manner.
   
   
6. The annual and final fiscal reports or vouchers requesting payment under a sponsored agreement must include a certification, signed by an official who is authorized to legally bind the University, which reads as follows: “By signing this report, I certify to the best of my knowledge and belief that the report is true, complete, and accurate, and the expenditures, disbursements and cash receipts are for the purposes and objectives set forth in the terms and conditions of the Federal award. I am aware that any false, fictitious, or fraudulent information, or the omission of any material fact, may subject me to criminal, civil or administrative penalties for fraud, false statements, false claims or otherwise.” 2 CFR 200.415(a). PIs and other faculty are not authorized to bind the University; the certification must be by the Provost/Executive Vice President for Academic Affairs.

RESPONSIBILITIES:

1. Effort Coordinators must:
   1. Understand federal requirements related to Effort.
   2. Monitor Effort commitments, salary charges and cost sharing on all applicable awards.
   3. Follow up with faculty, staff and payroll coordinators to make adjustments to Effort reports as necessary.
   4. Communicate to the central sponsored programs office any changes that require sponsor notification and/or approval.
   5. Review salary charges with faculty and staff and post any salary distribution updates and/or corrections in a timely manner.
   6. Check Effort reports and project statements for accuracy during the review period.
   7. Monitor that Effort certifications are completed within 60 days after release to the certifier, and that recertifications are completed within 30 days after release to the certifier.
      
      
2. Certifiers (PIs, faculty and staff) must:
   1. Understand federal requirements related to Effort.
   2. Ensure the appropriateness and accuracy of all Effort expended on sponsored projects.
   3. Review, initiate corrections when necessary, and electronically certify Effort report(s) during the 60-day certification period.
   4. Communicate significant Effort changes (over 5% and more than $100 per line threshold) to their Effort coordinator(s).
   5. Recertify Effort report(s) in the 30-day recertification period, if Effort changes over the threshold are made after a report has been certified.
   6. On federal projects, obtain prior approval if disengaged from the project for more than three consecutive months or if Effort is reduced more than 25% from the budget awarded.
      
      
3. ORSP must:
   1. Implement the Effort Reporting Policy and develop corresponding procedures.
   2. Develop educational programs for all employees involved in the Effort certification process.
   3. Ensure that the Effort system produces accurate Effort statements in a timely manner.
   4. Monitor system to ensure compliance.
   5. Monitor the Effort process for timely submission and report findings to departments.
      
      
4. Principal Investigators must also:
   1. Certify project statements of graduate students and temporary employees to accurately reflect their Effort during Effort period.
   2. Ensure faculty and staff appointed to their sponsored projects certify within the (re)certification period(s).

COMPLIANCE WITH THIS POLICY:

1. Failure to comply with this policy can result in project costs being disallowed, as well as fines and penalties imposed by the funding agencies. For assistance with compliance, please contact ORSP.
   
   
2. Noncompliance can also result in the University suspending support for extramural activities on behalf of individuals who do not fulfill their Effort Reporting responsibilities, including PIs who do not ensure the faculty and staff on their projects have certified. Specifically, the University will not:
   1. Submit a grant proposal/application to sponsors for extramural projects if individuals who are in violation of the certification period deadline are listed as personnel in the application.
   2. Execute award agreements and establish accounts for projects that have individuals who are in violation of the certification period deadline listed as personnel in the application.

 RELATED LAWS, POLICIES & PROCEDURES:

1. S. Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance for Federal Awards), 2 CFR Part 200
2. CSU Pueblo Policy on Institutional Base Salary
3. CSUP Conflict of Interest and Commitment Policy.

HISTORY OF REVISIONS:

Adopted: September 23, 2024